
	Year Ended December 31,
	2020		2019		2018
Current:
Federal	$	(5)	$	3	$	(13)
State	13		7		5
Foreign	2		1		2
Total current	10		11		(6)
Deferred:
Federal	(66)		4		62
State	(48)		(1)		9
Foreign	—		—		—
Total deferred	(114)		3		71
Income tax (benefit) expense	$	(104)	$	14	$	65


	Year Ended December 31,
	2020		2019		2018
Federal statutory rate	21	%	21	%	21	%
State and local income taxes, net of federal tax benefits	3		6		6
Discontinued operations—establishment/reversal of deferred tax liability (a)	10		(26)		—
Non-deductible equity compensation	(2)		(4)		2
Non-deductible executive compensation	(1)		(1)		1
Goodwill impairment	(7)		(3)		—
Meals & entertainment	—		(1)		1
Uncertain tax positions	—		—		(1)
Net change in valuation allowance	(1)		—		2
Effective tax rate	23	%	(8)	%	32	%

(a)See Note 1, "Basis of Presentation—Inclusion of Cartus Relocation Services in Continuing Operations". This item reflects the tax impact from the 2019 recognition of gain on the pending sale of Cartus Relocation Services (previously recorded in discontinued operations) and the 2020 de-recognition of that gain.

Deferred income taxes result from temporary differences between the amount of assets and liabilities recognized for financial reporting and tax purposes. The components of the deferred income tax assets and liabilities, as of December 31, are as follows:


	2020		2019
Deferred income tax assets:
Net operating loss carryforwards	$	124	$	177
Tax credit carryforwards	26		29
Accrued liabilities and deferred income	88		77
Operating leases	151		169
Minimum pension obligations	19		18
Provision for doubtful accounts	9		7
Liability for unrecognized tax benefits	1		1
Interest rate swaps	21		12
Total deferred tax assets	439		490
Less: valuation allowance	(21)		(17)
Total deferred income tax assets after valuation allowance	418		473
Deferred income tax liabilities:
Depreciation and amortization	553		704
Operating leases	119		146
Prepaid expenses	9		8
Basis difference in investment in joint ventures	11		2
Other	1		2
Total deferred tax liabilities	693		862
Net deferred income tax liabilities	$	(275)	$	(389)

The net deferred income tax liability of $275 million as of December 31, 2020 is included in the accompanying Consolidated Balance Sheets with $276 million in deferred income taxes (non-current liabilities) and $1 million in other non-current assets. The net deferred income tax liability of $389 million as of December 31, 2019 is included in the accompanying Consolidated Balance Sheets with $390 million in deferred income taxes (non-current liabilities) and $1 million in other non-current assets.

As of December 31, 2020, the Company had gross federal and state net operating loss carryforwards of $368 million. The federal net operating loss carryforwards expire between 2030 and 2033, and the state net operating loss carryforwards expire between 2024 and 2035.

The Company utilizes the FASB guidance for accounting for uncertainty in income taxes, which prescribes a recognition threshold and a measurement attribute for the financial statement recognition and measurement of tax positions taken or expected to be taken in a tax return. The Company reflects changes in its liability for unrecognized tax benefits as income tax expense in the Consolidated Statements of Operations. As of December 31, 2020, the Company’s gross liability for unrecognized tax benefits was $19 million, of which $17 million would affect the Company’s effective tax rate, if recognized. The Company does not expect that its unrecognized tax benefits will significantly change over the next twelve months.

The Company files U.S., state and foreign income tax returns in jurisdictions with varying statutes of limitations. Tax returns for the 2006 through 2020 tax years remain subject to examination by federal and certain state tax authorities. In significant foreign jurisdictions, tax returns for the 2010 through 2020 tax years generally remain subject to examination by their respective tax authorities. The Company believes that it is reasonably possible that the total amount of its unrecognized tax benefits could decrease by $2 million in certain taxing jurisdictions where the statute of limitations is set to expire within the next twelve months.

The Company recognizes accrued interest and penalties related to unrecognized tax benefits in interest expense and operating expenses, respectively. The Company did not recognize a change of interest expense for the year ended December 31, 2020. Additionally, the Company did not recognize a change of interest expense for the year ended December 31, 2019 and recognized a reduction of interest expense of $1 million for the year ended December 31, 2018.


Unrecognized tax benefits—January 1, 2018	$	22
Reduction due to lapse of statute of limitations	(2)
Unrecognized tax benefits—December 31, 2018	20
Gross increases—tax positions in prior periods	1
Reduction due to lapse of statute of limitations	(1)
Unrecognized tax benefits—December 31, 2019	20
Reduction due to lapse of statute of limitations	$	(1)
Unrecognized tax benefits—December 31, 2020	$	19

The Company is subject to income taxes in the United States and several foreign jurisdictions. Significant judgment is required in determining the worldwide provision for income taxes and recording related assets and liabilities. In the ordinary course of business, there are many transactions and calculations where the ultimate tax determination is uncertain. The Company is regularly under audit by tax authorities whereby the outcome of the audits is uncertain. The Company believes there is appropriate support for positions taken on its tax returns. The liabilities that have been recorded represent the best estimates of the probable loss on certain positions and are adequate for all open years based on an assessment of many factors including past experience and interpretations of tax law applied to the facts of each matter. However, the outcomes of tax audits are inherently uncertain.

Under the Tax Sharing Agreement with Cendant, Wyndham Worldwide and Travelport, the Company is generally responsible for 62.5% of payments made to settle claims with respect to tax periods ending on or prior to December 31, 2006 that relate to income taxes imposed on Cendant and certain of its subsidiaries, the operations (or former operations) of which were determined by Cendant not to relate specifically to the respective businesses of Realogy, Wyndham Worldwide, Avis Budget or Travelport. With respect to any remaining residual legacy Cendant tax liabilities, the Company and its former parent believe there is appropriate support for the positions taken on Cendant’s tax returns. However, tax audits and any related litigation, including disputes or litigation on the allocation of tax liabilities between parties under the Tax Sharing Agreement, could result in outcomes for the Company that are different from those reflected in the Company’s historical financial statements.